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The case of Hudson v. Michigan became one of the most controversial hearings in the history of the Supreme Court of the United States. When the police entered Hudson’s home, they violated the knock-and-announce rule while executing their search warrant. It was crucial that the Supreme Court did not exclude the evidence from the case even though the Fourth Amendment was violated by the police officers responsible for searching Hudson’s location (FindLaw, 2006). Thus, the Court ruled that the constitutional violation was not contradictory, as it would have been possible for officers to obtain the evidence if they had knocked as well.
Based on the US Constitution, the Fourth Amendment pronounces that people have the right to be secure in their persons against unreasonable seizures. Ultimately, the Fourth Amendment also gives citizens the right to have an opportunity to open the door prior to a search embedded in it, with police officers being required to announce their presence as well. Nevertheless, there have been numerous exclusionary rules introduced to adjust the Fourth Amendment and promote un-accountability in terms of the use of the knock-and-announce rule.
A thorough analysis of Hudson v. Michigan showed that the search completed by the police officers was unconstitutional due to the lack of a warrant allowing them to conduct the search in the first place. Accordingly, the unassailable nature of the need for but-for causations was one of the primary reasons for the majority votes (FindLaw, 2006). The discovery of the challenged evidence became an exceptional predicate because it allowed the Judges to treat the law enforcement officers as trespassers, excluding all the unlawfully obtained evidence from the case. Hence, it can be deemed appropriate to question the validity of seeing those police officers as mere trespassers despite all the exclusionary rules. It can be hypothesized that the Court should have taken a different approach to the given constitutional violation in order to alter the process of obtaining evidence and preventing the occurrence of cases where unnecessary altercations occur, resulting in human casualties.
The opinion written by Justice Scalia perceived both the exclusionary rule and the knock-and-announce rule as valid, making the Hudson v. Michigan case even more complex. The majority held that the seizure of evidence was not associated with the violation of the knock-and-announce rule mentioned in the US Constitution (FindLaw, 2006). The rationale for the majority’s decision was that the police had to prevent violence in the first place, with a warrantless search being an inferior feature. Accordingly, the benefits of deterrence were overrun by the exclusionary rule that led to the violation of the Fourth Amendment, with an argument revolving around the benefits of internal police discipline and civil suits.
The dissenting opinion, written by Justice Breyer, was based on the supposition that the exclusionary rule has been upheld for an incredibly long period, and it was crucial to terminate such opportunities in the future. There was a doubt expressed by the dissent, which revolved around the inability to exclude the evidence obtained during a search from the violations of the knock-and-announce rule (FindLaw, 2006). It was rather evident that qualified immunity could have protected most of the officers who had violated the same rule in the past, meaning that no-knock warrants were empowered by the Supreme Court and the absence of actions taken against the unbalanced criminal justice system. With limited accountability and a tangible carte blanche given to police officers, the precedent of Hudson v. Michigan was crucial for the Supreme Court due to the promotion of bad police practices.
The difference between the majority and the dissenting opinion leaves enough room for a detailed discussion on how similar cases could be resolved in future Supreme Court proceedings. The incredible grade of authority that the Supreme Court assigns to law enforcement officers is not mitigated rationally, causing the occurrence of police shootings to increase – regardless of whether citizens were armed or not (Oppel Jr, 2021). Therefore, the use of force could be perceived as not connected to the Fourth Amendment, allowing police officers to engage in more cases that involve the violation of the knock-and-announce rule.
Based on the existing statistics, there has been a significant increase in the number of no-knock warrants used against minority populations. According to Oppel Jr (2021), this disproportion was one of the main contributors to the killing of Breonna Taylor and a rational continuation of the issue that was sparked by the Supreme Court during the Hudson v. Michigan case. Even though the first no-knock warrants were passed at the dawn of the war on drugs, they have not been altered in any significant way to reflect contemporary realities. Thus, there has to be an assumption that the outcome of the Hudson v. Michigan case might have been one of the factors that eventually contributed to Breonna Taylor being killed (Oppel Jr, 2021). Poorer communities seem to be disregarded by the Supreme Court decisions, and Taylor’s death is one of the indicators that no significant changes in criminal justice have occurred since Hudson v. Michigan.
Upon reviewing the case of Breonna Taylor, it can be found that the presumption of innocence can be bypassed through the violation of the knock-and-announce rule entrenched in the Fourth Amendment. Therefore, the Constitution of the United States represents an instrument that can be utilized by the Judges of the Supreme Court to override certain rules and apply exclusionary instructions to preserve law enforcement officers (Oppel Jr, 2021). Even if it is not a universal rule, it is important to look at the Fourth Amendment through the prism of Hudson v. Michigan and Breonna Taylor’s death because constitutional violations seemingly reward similar crimes. For the criminal justice system, it means that there is no particular way to escape a no-knock warrant, especially if police officers are rather unlikely to be punished for violating the US Constitution.
Overall, it can be concluded that the presence of exclusionary rules weakens the Fourth Amendment and affects the Judges of the Supreme Court to an extent where questionable decisions have to be made. The case of Hudson v. Michigan and the killing of Breanna Taylor both showed that the problem of the knock-and-announce rules and requirements is going to remain unsolved unless new adjustments are made to the existing legislation. There is no particular guarantee that no-knock warrants are not going to be used in the future for registered gun owners and home foreclosures. The notion of objective reasoning, as applied to officers’ actions, should be held under scrutiny as well. Nevertheless, it should be considered without paying attention to officers’ motivation and the underlying intent.
References
FindLaw. (2006). Hudson v. Michigan. Web.
Oppel Jr, R. (2021). What to know about Breonna Taylor’s death. nytimes.com. Web.
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